Catalyzing Economic Growth through SBA Community-Based Lending (House Small Business subcommittee hearing, March 29, 2022)
Summary
The House Small Business Subcommittee on Economic Growth, Tax, and Capital Access, chaired by Representative Sharice Davids, heard three community lenders on March 29, 2022: Manny Flores of SomerCor, Kerry Doi of the Pacific Asian Consortium in Employment (PACE) and Brooke Mirenda of the Sunshine State Economic Development Corporation (SEDCO). Chairwoman Davids said Congress put set-asides in legislation so community lenders could take part in PPP on equal footing with bigger banks, and that in later rounds the average loan size decreased substantially and more funding reached businesses in underserved markets. Ranking Member Dan Meuser said the 504 CDC program issued 185 loans in Pennsylvania last fiscal year for over $153 million and that the SBA has somewhat slow-walked the implementation of the 504 Express Program. The hearing is Small Business Committee Document Number 117–051.
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CATALYZING ECONOMIC GROWTH THROUGH SBA
COMMUNITY-BASED LENDING
HEARING
BEFORE THE
SUBCOMMITTEE ON ECONOMIC GROWTH,
TAX, AND CAPITAL ACCESS
OF THE
COMMITTEE ON SMALL BUSINESS
UNITED STATES
HOUSE OF REPRESENTATIVES
ONE HUNDRED SEVENTEENTH CONGRESS
SECOND SESSION
HEARING HELD
MARCH 29, 2022
Small Business Committee Document Number 117–051
Available via the GPO Website: www.govinfo.gov
U.S. GOVERNMENT PUBLISHING OFFICE
47–180 WASHINGTON : 2022
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HOUSE COMMITTEE ON SMALL BUSINESS
NYDIA VELÁZQUEZ, New York, Chairwoman
JARED GOLDEN, Maine
JASON CROW, Colorado
SHARICE DAVIDS, Kansas
KWEISI MFUME, Maryland
DEAN PHILLIPS, Minnesota
MARIE NEWMAN, Illinois
CAROLYN BOURDEAUX, Georgia
TROY CARTER, Louisiana
JUDY CHU, California
DWIGHT EVANS, Pennsylvania
ANTONIO DELGADO, New York
CHRISSY HOULAHAN, Pennsylvania
ANDY KIM, New Jersey
ANGIE CRAIG, Minnesota
BLAINE LUETKEMEYER, Missouri, Ranking Member
ROGER WILLIAMS, Texas
PETE STAUBER, Minnesota
DAN MEUSER, Pennsylvania
CLAUDIA TENNEY, New York
ANDREW GARBARINO, New York
YOUNG KIM, California
BETH VAN DUYNE, Texas
BYRON DONALDS, Florida
MARIA SALAZAR, Florida
SCOTT FITZGERALD, Wisconsin
MELISSA JUNG, Majority Staff Director
ELLEN HARRINGTON, Majority Deputy Staff Director
DAVID PLANNING, Staff Director
(II)
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CONTENTS
OPENING STATEMENTS
Page
Hon. Sharice Davids ................................................................................................ 1
Hon. Dan Meuser ..................................................................................................... 2
WITNESSES
Mr. Manny Flores, President and Chief Executive Officer, SomerCor, Chicago,
IL ........................................................................................................................... 4
Mr. Kerry Doi, President and Chief Executive Officer, Pacific Asian Consor-
tium in Employment (PACE), Los Angeles, CA ................................................ 6
Ms. Brooke Mirenda, President and Chief Executive Officer, Sunshine State
Economic Development Corporation (SEDCO), Clearwater, FL ...................... 7
APPENDIX
Prepared Statements:
Mr. Manny Flores, President and Chief Executive Officer, SomerCor,
Chicago, IL .................................................................................................... 19
Mr. Kerry Doi, President and Chief Executive Officer, Pacific Asian Con-
sortium in Employment (PACE), Los Angeles, CA .................................... 28
Ms. Brooke Mirenda, President and Chief Executive Officer, Sunshine
State Economic Development Corporation (SEDCO), Clearwater, FL ..... 39
Questions for the Record:
None.
Answers for the Record:
None.
Additional Material for the Record:
CUNA - Credit Union National Association ................................................... 47
NADCO - National Association of Development Companies ........................ 49
(III)
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CATALYZING ECONOMIC GROWTH THROUGH
SBA COMMUNITY-BASED LENDING
TUESDAY, MARCH 29, 2022
HOUSE OF REPRESENTATIVES,
COMMITTEE ON SMALL BUSINESS,
SUBCOMMITTEE ON ECONOMIC GROWTH,
TAX, AND CAPITAL ACCESS,
Washington, DC.
The Subcommittee met, pursuant to call, at 10:00 a.m., in Room
2360, Rayburn House Office Building and via Zoom, Hon. Sharice
Davids [chairwoman of the Subcommittee] presiding.
Present: Representatives Davids, Bourdeaux, Chu, Meuser,
Donalds, Young Kim, and Van Duyne.
Chairwoman DAVIDS. Good morning. I call this hearing to
order.
Without objection, the Chair is authorized to declare a recess at
any time.
I would like to begin by noting some important requirements.
Standing House and Committee rules and practice will continue to
apply during hybrid proceedings. All Members are reminded that
they are expected to adhere to these rules, including decorum.
House regulations require Members to be visible through a video
connection throughout the proceeding, so please keep your cameras
on. Also, please remember to remain muted until you are recog-
nized to minimize background noise.
In the event a Member encounters technical issues that prevent
them from being recognized for their questioning, I will move to the
next available Member of the same party and I will recognize that
Member at the next appropriate time slot provided they have re-
turned to the proceeding.
The COVID-19 pandemic highlighted long-standing inequities in
the small business lending market. In March of 2020, Congress
stepped in to support small businesses through the Paycheck Pro-
tection Program. Under PPP, banks and other private lenders
made fully guaranteed SBA loans to small businesses hurt by the
virus.
Over the life of the program, PPP delivered over $800 billion in
emergency loans. This aid helped small businesses keep employees
on payroll and pay necessary expenses like rent and utilities. But
as we heard last week in our Oversight Committee, it became clear
that access to the program was not equal for everyone.
Prior relationships with big banks led to the exclusion of the
smallest of small businesses, putting them at risk of closing perma-
nently.
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One of our top priorities for this Committee was empowering
community lenders to originate more PPP loans to maximize lend-
ing in underserved communities. These institutions typically have
deep ties to the smallest businesses.
We incorporated set-asides in multiple pieces of legislation to al-
locate funds so that community lenders could participate in PPP on
equal footing with bigger banks.
Both the GAO and outside experts found these changes proved
to be effective in making the program more accessible.
In later rounds of PPP, the average loan size decreased substan-
tially, and more funding reached businesses in underserved mar-
kets.
Moreover, small firms reported the highest level of satisfaction
with community-based lenders and small banks.
The ability of community lenders to reach underserved busi-
nesses should serve as an important lesson moving forward.
Though the PPP portal closed last May, these community lenders
can be a vital tool as we work to drive an equitable recovery. In
fact, many of the community lenders that helped deliver PPP to un-
derserved businesses are already active in SBA lending programs.
Programs like the 504/CDC Loan Program, SBA Microloan Pro-
gram, and Community Advantage pilot loan program are all deliv-
ered by community lenders. Each program has proven effective in
helping deliver capital to underserved communities.
By strengthening existing SBA programs that utilize community
lenders, we can help ensure that all small firms have access to the
capital they need to grow and thrive.
Members of this Committee have introduced and advanced nu-
merous pieces of legislation to bolster these programs to better
serve entrepreneurs.
Today, I look forward to taking a close look at these proposals
and hearing directly from community lenders about the issues that
they face and what we can do to help.
I would now like to yield to the Ranking Member Mr. Meuser for
his opening statement.
Mr. MEUSER. Thank you very much, Madam Chair. And thank
you for holding this hearing on small business access to capital. It
is and will remain one of the top issues for this Committee.
Over the last few years, main street businesses across our vast
nation have experienced one hurdle after another. COVID-19 shut-
downs devastated our country’s small businesses, entrepreneurs,
and startups. From forced closures to capacity restrictions, busi-
ness owners were confronted with a challenging path forward. In
response to the emergency period, former President Trump and
Congress enacted numerous small business relief measures, includ-
ing the popular Paycheck Protection Program that was delivered to
small businesses through a joint effort with private sector lenders.
Today, small businesses are facing economic headwinds that are
preventing their recovery and growth. If it is not scorching inflation
price increases, small businesses are facing supply chain disrup-
tions that are preventing goods from reaching their shelves.
On top of ever-increasing costs, small businesses continue to
have trouble finding employees. All you have to do is enter a small
business and they will be sure to inform you of that. These are not
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the economic conditions that instill confidence into a sector of our
economy that produces nearly half of the country’s gross domestic
product and comprises over 99 percent of all businesses in the na-
tion.
Despite these obstacles, small businesses can lead our nation
back to economic growth. In order to do this, however, we must en-
sure the lending environment is healthy, robust, and responsible.
That is why a public-private partnership lending model must con-
tinue to be the model of choice for our country when it comes to
federal access to capital programs. Involving the private sector is
the best way to produce efficiencies that cannot be matched or
equaled by strictly the federal government.
Furthermore, private sector lenders act as centennials against
fraud. Anything less has proven to be very problematic and frank-
ly, is unacceptable.
One example of this public-private partnership is through the
SBA’s 504 CDC loan program. This program, which focuses on eco-
nomic development, reached record highs last fiscal year while
serving small businesses and communities across the nation.
In my state, Pennsylvania, the program issued 185 loans last fis-
cal year for over $153 million. It does not seem all that significant
but extremely significant to the 185 recipients of those loans.
Again, this is an economic development-driven program; therefore,
each loan requires a job creation goal or community development
goal to be met. While the program continues to be successful, there
is more work that needs to be done, especially when it comes to the
management of the program by the SBA.
The turn time on delivering loans to small business owners con-
tinues to grow, which is concerning, and the SBA has somewhat
slow-walked the implementation of the 504 Express Program which
it was enacted in a bipartisan manner over a year ago.
Madam Chair, I would like to note that when Republicans asked
about the delays in launching this new tool, all we received back
from the SBA is that it would be implemented soon. This is really
not acceptable. Small businesses are working tirelessly to serve
their communities. Unfortunately, the actions of this administra-
tion did not always suggest that they are putting the nation’s job
creators at the forefront. From the SBA inadequately answering
our questions to the Treasury Secretary ignoring this Committee,
which I think upsets both sides of the aisle and small businesses,
by refusing to testify, again, despite what the law requires. This
administration must do better.
With that, Madam Chair, I would like to thank you for holding
this hearing, and I am looking forward to the conversation on how
a public-private partnership lending models can successfully de-
liver capital to the nation’s job creators and the communities that
they serve.
And I yield back.
Chairwoman DAVIDS. Thank you. The gentleman yields back.
And with that, I would like to introduce one of our witnesses.
Our first witness is Mr. Manny Flores, president and chief execu-
tive officer of SomerCor, an SBA-certified development company lo-
cated in Chicago, Illinois. In addition to making 504 loans,
SomerCor is an active lender in the SBA Community Advantage
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pilot loan program. SomerCor also participates in the City of Chi-
cago’s Small Business Improvement Fund which promotes economic
development by providing small firms in Chicago with reimburs-
able grants for permanent building improvement costs. SomerCor
is a Member of the National Association of Development Compa-
nies (NADCO) and we are glad to have you with us today. Wel-
come, Mr. Flores.
And I will now yield to the Ranking Member.
Sorry about that.
Our second witness is Mr. Kerry Doi, the president and chief ex-
ecutive officer of the Pacific Asian Consortium in Employment
(PACE), located in Los Angeles, California. PACE is a Treasury
certified community development financial institution (CDFI) and
an SBA microloan intermediary and Community Advantage lender
focusing on supporting primarily Asian American entrepreneurs
and those from underserved communities. PACE is also a Member
of the Friends of the SBA Microloan Program, a nationwide net-
work of nonprofit microlending intermediaries focused on economic
development.
Welcome, Mr. Doi, and we look forward to your testimony.
I would now like to yield to the Ranking Member, Mr. Meuser,
to introduce our third and final witness.
Mr. MEUSER. Thank you again, Madam Chairwoman.
Our next witness is Brooke Mirenda. Ms. Mirenda is the presi-
dent and chief executive officer of Sunshine State Economic Devel-
opment Corporation, also known as SEDCO, based in Clearwater,
Florida. SEDCO is a nonprofit CDC that participates in the SBA’s
504 Loan Program. With over 15 years of financial services and
banking experience, Ms. Mirenda also serves on the Legislative
Committee with the National Association of Development Compa-
nies, the main trade association for the 504 Loan Program. Addi-
tionally, Ms. Mirenda serves on numerous community boards
throughout the State of Florida.
Ms. Mirenda, we are glad to have you back before the Com-
mittee. Your extensive experience in the area of economic develop-
ment lending will benefit this conversation immensely.
And Madam Chairwoman, I yield back.
Chairwoman DAVIDS. Thank you. The gentleman yields back.
And thank you to all our witnesses for being here today.
Mr. Flores, you are now recognized for 5 minutes.
STATEMENTS OF MANNY FLORES, PRESIDENT AND CHIEF EX-
ECUTIVE OFFICER, SOMERCOR; KERRY DOI, PRESIDENT
AND CHIEF EXECUTIVE OFFICER, PACIFIC ASIAN CONSOR-
TIUM IN EMPLOYMENT (PACE); BROOKE MIRENDA, PRESI-
DENT AND CHIEF EXECUTIVE OFFICER, SUNSHINE STATE
ECONOMIC DEVELOPMENT CORPORATION (SEDCO)
STATEMENT OF MANNY FLORES
Mr. FLORES. Good morning, Chairwoman Davids, Ranking
Member Meuser, and Members of the Subcommittee. Thank you for
the privilege of testifying before you today to discuss the Small
Business Administration community-based lending programs.
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My name is Manuel Flores, and I am here on behalf of
SomerCor, a Certified Development Company based in Chicago, Il-
linois. There are more than 200 nonprofit CDCs nationwide work-
ing in their communities to deliver the SBA’s 504 loan program, as
well as other SBA resources like the 7(a) Community Advantage
and Microloan programs.
CDCs are required to invest in economic development initiatives
in their areas of operation beyond their participation in the SBA
504 program. To use SomerCor as an example, not only are we one
of the nation’s larger CDCs by annual loan volume, we also partici-
pate in the SBA’s Community Advantage loan program and admin-
ister small business grants on behalf of the City of Chicago for new
investments in under-resourced communities.
We are part of a national CDC network that plays an integral
role through a mission-based lens in growing economic develop-
ment in communities across our nation. The SBA 504 loan program
is a public-private partnership that brings together traditional
lenders and CDCs to help small businesses finance the acquisition
of commercial real estate, make building improvements, and pur-
chase equipment with terms typically not available conventionally.
The program provides loans of up to $5 million and $5.5 million for
certain industries. The hallmarks of the program include terms of
10 years for equipment and 25 years for real estate with a fixed,
below market interest rate.
In the wake of the COVID-19 pandemic and our ongoing eco-
nomic recovery, I want to take this opportunity to highlight three
policy considerations. First and foremost, it is critical for the 504
program to remain open and viable. Increased loan demand under
the 504 program exceeded its then-congressionally authorized cap
of $7.5 billion in fiscal year 2021, effectively shutting the program
down for 3 weeks, causing a myriad of negative issues for small
businesses. In fiscal year 2022, program demand continues at an
unprecedented rate. We are extremely thankful Congress increased
the 504 program authorization level to $11 billion for the remain-
der of fiscal year 2022, averting a significant disruption in the mar-
ket.
It is important, however, for Congress to take new steps now to
avoid a program shutdown in the future as we anticipate continued
growth and demand. As a zero subsidy program that encourages
small business expansion, our ask is for certainty and the ability
to meet rising demand long term. A step in the right direction is
to combine the authorization levels of the regular 504 program and
the refi without expansion programs so all 504 programs are under
the same authorization level of $15 billion.
My second recommendation is for passage of the 504 Moderniza-
tion and Small Manufacturer’s Act of 2021, H.R. 1490, which in-
creases the 504 loan for manufacturers to $6.5 million, decreases
the borrower equity injection from 10 to five percent, and includes
other provisions that support small businesses in the manufac-
turing sector.
I want to be clear that we have an opportunity to do more to
catalyze increased investment in new manufacturing here in the
United States. The pandemic and global supply chain disruptions
laid bare the need for a stronger and more resilient domestic man-
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ufacturing sector. H.R. 1490 may provide more capital to help
strengthen our manufacturing industry.
Finally, we recommend adoption of NADCO’s request to make
the Community Advantage program permanent with provisions to
set it for long-term success. This includes training for new Commu-
nity Advantage lenders and viable solutions to alleviate liquidity
issues that constrain the lending capacity of nonprofit CDCs. The
Community Advantage program has been a pilot since 2011, but for
the program to be successful, lenders and borrowers need certainty
on the continuity of the program.
Sitting here before you is an honor, and I do so in the spirit of
advocating for small businesses who help build our communities.
One such example is SomerCor client Osorio Metals Supply, a fam-
ily-owned business in Chicago started by Rubin Osorio in 1992 as
a one-man operation working out of his garage. This past year,
Rubin and his daughter Adriana, who is now the company’s chief
operating officer, turned to SomerCor for an SBA 504 loan to make
needed renovations to their 30,000 square foot facility. Now, Osorio
Metals has a state-of-the-art facility to better serve its clients. And
as Adriana said, and I quote, ‘‘Acquiring a new facility and trans-
forming the space to fit our needs has been a dream come true for
our family business and it would not have been possible without
this program.’’
It is these businesses and projects that inspire our work. Again,
thank you for the opportunity to testify here today, and I look for-
ward to answering your questions.
Chairwoman DAVIDS. Thank you, Mr. Flores.
And Mr. Doi, you are now recognized for 5 minutes.
STATEMENT OF KERRY DOI
Mr. DOI. Thank you, Madam Chair, Representative Meuser, my
Congresswoman Judy Chu, honorable Members of the Committee.
I am Kerry Doi, CEO of PACE. Thank you for this opportunity to
testify before the House Small Business Committee on the all-im-
portant catalyzing economic growth through SBA community-based
lending.
PACE was incorporated in 1976, and in 1993, began providing
business development services to pre-startups, microenterprises,
and small businesses. Since inception, PACE Business has trained
or counseled more than 68,000 pre-startups, startups, operating
micro and small businesses who have established or expanded over
17,000 small businesses that have created or retained over 22,000
jobs.
For over 28 years, PACE has provide comprehensive wraparound
services to more than 68,000 businesses across L.A. County.
The SBA microloan program, which was authorized in 1991 to
businesses that conventional lenders were and remain unable to fi-
nance for a variety of reasons, including lack of sufficient collateral
or business experience. Nonprofit community-based intermediary
lenders use the SBA microloan program to finance new and emerg-
ing businesses in urban and rural communities and eventually
moved these businesses into the economic mainstream as bankable
ventures.
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The average SBA microloan was $14,435 in FY2020. There are
144 active microloan intermediaries serving 49 states, the District
of Columbia, and Puerto Rico. In FY21 alone, microlenders made
an additional 4,510 loans totaling over $74 million. Of this amount,
63 percent went to existing businesses, 36.9 percent to startups, 48
percent to woman-owned businesses, 66.9 percent to minority-
owned enterprises.
This financing led to the creation of 7,500 jobs and the retention
of over 10,000 jobs.
Despite intermediaries serving at-risk small businesses, the SBA
microloan program has a cumulative default rate of less than 2
percent. PAC’s SBA microloan program started in 2010. Since the
program launched, our loan team has deployed 323 loans for $3.3
million, with an average loan size of $10,156. As of March 15, 2022,
we have 32 SBA microloans in our portfolio totaling $548,472, or
an average loan size of $17,139.
We reviewed H.R. 1487 and H.R. 1502. H.R. 1487 establishes a
series of reporting requirements for SBA and requires an annual
report on the effectiveness of the microloan program. H.R. 1502
makes a number of improvements and updates the microloan pro-
gram, which we support. Of particular note, it raises the definition
of small loans from $7,500 to $10,000.
In addition, it establishes loans of 7 years for loans of $10,000
or less, and up to 10 years for loans that are greater than $10,000.
Reviewing the allocation for SBA funds is important by reserving
the first 2 quarters of the fiscal year, 15 percent of the annual
microloan appropriation for unutilized states.
One issue that the bill does not address is the Executive Order
mandating language access that we would urge the Committee to
consider. Otherwise, we fully support the bill and the microloan
program which has proven itself to be an important tool for eco-
nomic development. Thank you.
Chairwoman DAVIDS. Thank you, Mr. Doi.
Ms. Mirenda, you are recognized for 5 minutes.
STATEMENT OF BROOKE MIRENDA
Ms. MIRENDA. Chairwoman Davids, Ranking Member Meuser,
and Members of the Subcommittee, thank you for inviting me to
join in the conversation on community-based lending and the work
CDCs are doing to build communities across the U.S.
My name is Brooke Mirenda, and I am here on behalf of Sun-
shine State Economic Development Corporation (SECD), located in
Clearwater, Florida, and I serve as the president and CEO. I re-
main intimately involved in ensuring the capital access needs of
borrowers are being met, primarily via the SBA 504 loan program.
I am also a Member of the National Association of Development
Companies (NADC)), a trade organization dedicated to supporting
the CDC industry and our collective work in the economic develop-
ment arena. The SBA 504 loan program not only creates jobs in our
economy, it also offers beneficial rates and terms for our small
business owners, helping them to preserve capital and grow their
businesses while operating at a zero subsidy. Because the core pur-
pose of the program is economic development, all 504 borrowers
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must meet at least one of two specified economic development ob-
jectives which are outlined in my written testimony.
In fiscal year 2021, the 504 program delivered more than $8.2
billion in financing to 9,700 businesses. The creation of retention
of 85,000 jobs and a total capital investment of over $20 billion. In
fact, we served so many small businesses that we reached our
then-Congressional authorized cap of $7.5 billion on September
7th, and SBA was unable to approve any 504 loans until the fiscal
year authorization levels reset October 1st.
Volume did not dissipate in fiscal year 2022, and we began rais-
ing with NADCO to raise our concerns about another much longer
much longer shutdown of the program. Thankfully, Members of
this Committee, as well as our counterparts in the Senate, came to-
gether to work with appropriators to ensure businesses have access
to the job creating financing they need by increasing the authoriza-
tion level for the regular 504 program to $11 billion for the remain-
der of the fiscal year.
I want to take a moment to share my sincere thanks for all the
effort put into making this increase a reality. Our borrowers, our
lenders, and our CDCs thank you.
I believe a major reason the 504 program continues to grow is
the program is a prime example of how public-private partnerships
should work. The SBA administers the program and we, the pri-
vate sector nonprofits focused on economic development, partner
with private sector lenders to deliver the program. The CDC and
lending partner each complete full loan underwriting which is then
reviewed by the SBA. As a result, small business owners are not
repaying their debts. The 504 has a charge off rate of $.6 percent
over the last 10 years. Because of the soundness of the program,
the costs associated with it are paid for by fees so it does not cost
taxpayers any money.
The program is performing extremely well and providing much
needed capital to our nation’s job creators, small businesses. How-
ever, there are considerations Congress should keep in mind to
make sure it stays successful. First and foremost, the program
needs to stay open. I, along with NADCO, urge Congress to work
together to come to a long-term solution to the 504 authorization
level including combining the regular 504 and debt refinance with-
out expansion caps. It would be devastating to small businesses
and to the reputation of the program if the program would have
shut down for any period of time.
Secondly, as a result of the increased profile at the SBA and the
economic impacts of the pandemic on small businesses, its lending
programs are experiencing increased demand. However, SBA is
largely operating with the same staffing levels as they were pre-
pandemic, and although they are working hard to keep up with the
demand of the program, over time and overworked staff is not a
permanent solution.
A solution is one passed by Congress in the Economic Aid Act
which is a pilot within the 504 program that would allow vetted,
proven CDCs with ALP status to more efficiently process loans up
to $500,000. SEDCO alone would have been able to process 51 per-
cent of our loans under this program. The CDC industry is still
awaiting the rule implementation which is to sunset in fiscal year
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9
2023. NADCO and I recommend Congress extending the sunset to
fiscal year 2027 to allow it sufficient time to operate in order for
SBA and Congress to be able to make an informed determination
on its efficacy.
My final recommendation is for the implementation process of
laws that impact the SBA’s lending programs to include a dialogue
about congress intent. For example, Congress authorized changes
to the debt refinance without expansion program in the Economic
Aid Act. Those changes we believe were intended to bring parity
to the refinancing of government debt among SBA lending pro-
grams. However, the implementation of the debt refinance provi-
sions included parameters that limit the ability of CDCs to reach
as many small business owners as the changes should allow.
I sincerely appreciate the opportunity to bring these issues to
your attention and talk about a program that is doing phenome-
nally well with $4.48 billion in approved 504 loans as of March
18th.
I look forward to working with you to ensure the future success
of this public-private partnership and I am happy to answer any
questions.
Chairwoman DAVIDS. Thank you, Ms. Mirenda. And thank you
to all of our witnesses for joining us today. We appreciate your ex-
pertise and the recommendations and considerations that you’ve
shared with us.
So, I will begin by recognizing myself for 5 minutes.
So, even as we have seen a booming economy in this last year,
the reality is that a lot of small business owners are still facing
some pretty enormous challenges. Whether that is from inflation or
supply chain shortages, a lot of small businesses are still working
with very slim margins and pretty uncertain nods.
Mr. Flores, as a 504 and Community Advantage lender, you are
able to offer small businesses the full range of eligible loan uses
from long-term fixed asset and real estate financing to the 504 pro-
gram working capital in the Community Advantage Program. With
the broad range of eligible uses, how do the SBA community lend-
ing programs help small businesses compete amid growing uncer-
tainty around things like energy prices and other costs?
And Ms. Mirenda, if you want to chime in after.
Mr. FLORES. Thank you, Madam Chair, for that question.
In my opinion and my view and in my experience in seeing first-
hand how these programs work, it is about providing stability. In
particular, the 504 program, because you have these long terms as-
sociated with it, it allows businesses for better planning, for pre-
serving capital, and it is also affordable financing. With regards to
the Community Advantage Loan program, it is a $50,000 to
$250,000 loan program as you know, and that is, frankly, it is a
challenging type of loan to find conventionally. So, we can fill a gap
in the market to be able to assist these small businesses. And in
particular, we are looking to support businesses in low- and mod-
erate-income communities as part of that initiative.
So, it really provides additional support for these businesses that
frankly without these programs, they would not have those capital
options.
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Chairwoman DAVIDS. And so, I am curious with the mixture
and breadth that you both see in the work you are doing. Can you
talk a little bit about the ability to both plan long term, or longer
term, while also being kind of flexible and adaptable to the eco-
nomic environment that we have seen and the ways that you all
engage with your clientele?
Mr. FLORES. So, Madam Chair, the Certified Development Com-
pany Network is made up of companies that are working directly
in their neighborhoods and communities. And while we take a lot
of pride in providing very high quality expertise in the lending
process, we also, oftentimes, provide technical assistance. Working
hand-in-hand with chambers of commerce and other important
community stakeholders in making sure that people are made
aware of the resources that the Small Business Administration of-
fers, but then also providing some very direct support in how to ac-
cess these loans. How to become loan ready if you are not at a
point in your business to be able to access a 504 loan. Or with
these businesses on how to engage in better planning. We view our-
selves as strategic partners in all areas related to economic devel-
opment and support of strengthening a small business ecosystem.
And we do so, again, in reinforcing not only the partnership with
organizations such as chambers of commerce, but also with other
lending partners * banks, credit unions * that also play an integral
role in the deployment of these programs along with CDCs.
Ms. MIRENDA. So thank you for the question. And we are a
Community Advantage lender as well. We have funded a little over
$2 million just this year in Community Advantage loans.
The other thing is he mentioned management technical assist-
ance. Just so you guys know, that is a requirement on the Commu-
nity Advantage Loan program. So, we have to, every quarter, we
talk with our borrowers and discuss how their financials are going.
What does their P&L look like? What does their balance sheet look
like? Do they have any questions? Have they been able to hire any
folks? Things like that. So, I just wanted to bring that to your at-
tention.
The other thing, too, as far as lenders go, a lot of our deals do
come from our bankers. They know about the CA loan program.
There are deals that they cannot do conventionally so they will
refer deals out to us, you know, for a startup and things like that.
Chairwoman DAVIDS. It takes an ecosystem. And I will yield
back and recognize our Ranking Member, Mr. Meuser, for 5 min-
utes.
Mr. MEUSER. Thank you, Madam Chairwoman, very much. Mr.
Flores, Ms. Mirenda, thanks for being with us, as well to other tes-
tifier. I appreciate it.
So, I have to say, I like what I am hearing from my years in
business and working with small businesses and growing a small
business into a large business. You know, when you read things
such as I think it is barely 18 percent of small businesses seeking
loans or lines of credits, line of credit, actually get what they want
and what is sufficient. Having this SBA service and public-private
partnership that has worked with you folks is very important, so
I want to try to move through some questions relatively quickly if
we can.
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So, Ms. Mirenda, how many businesses do you work with?
Ms. MIRENDA. How many businesses do we work with?
Mr. MEUSER. Yes. How many loans do you extend? How many
businesses do you——
Ms. MIRENDA. Last year we approved 61 loans.
Mr. MEUSER. Sixty-one.
Ms. MIRENDA. Over the State of Florida.
Mr. MEUSER. How about you, Mr. Flores?
Mr. FLORES. Our current portfolio is more than $430 million.
We right now are on pace to reach $150 million. So, $130, $150
million in loan originations in the 504 program.
Mr. MEUSER. What is the average amounts? Ninety thousand?
One hundred thousand?
Mr. FLORES. For us in the 504 program, it is a loan amount of
about $800,000.
Mr. MEUSER. Eight hundred thousand.
Ms. MIRENDA. That is about right. Eight hundred thousand.
Mr. MEUSER. Okay. My mistake. Okay. And how many do you
deny? How many come in that you deny?
Ms. MIRENDA. A small amount. And the reason is because we
are usually getting referrals from our lending partners.
Mr. MEUSER. Okay.
Ms. MIRENDA. They are well-trained on what works and what
does not.
Mr. MEUSER. That is where most of them come——
Ms. MIRENDA. So that is where a lot of our deals come from,
exactly, from banks and credit unions.
Mr. MEUSER. So they clearly have other banking relationships?
Ms. MIRENDA. Absolutely. Yes.
Mr. MEUSER. For the most part?
Ms. MIRENDA. Yes.
Mr. MEUSER. Okay. So, we talked about some struggles, of
course, that small businesses have—workforce, inflation, energy
costs, taxes. I just want to ask you, the idea that the 100 percent
depreciation may end at the end of this year which certainly needs
to be extended and the idea that a C corporation may go from 21
percent federal income tax to 28 percent is certainly not in the in-
terest of small business because, as you well know, there’s well
over a million small businesses that are C corporations. Many com-
panies that were family businesses way back and others for various
reasons are C corporations. C corporation does not mean that they
are a multi-billion dollar business.
So just relatively quickly, tell me what struggles you are seeing,
because you deal with small businesses every day, what are you
hearing from your clients?
Ms. MIRENDA. So a few things come to mind. The first one is
interest rates are starting to rise. Our 504 loan program in the last
6 to 8 months has risen 1 percent. Now, we are still under 4 per-
cent so it is still a very low rate. However, I think we got a little
spoiled with 3 percent interest rates. So, our rate is still a little
under 4 percent for 25 years. So, they are getting squeezed there.
I would also say employees are costing more money. Obviously, the
rate has gone up for hourly employees. I was just talking to a fran-
chise owner about 2 weeks ago regarding this and their cost of
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goods is going up. So, what happens is price then go up. So, what
we are seeing is they are having trouble finding people and they
are seeing interest rates going up, so they are really trying to lock
in interest rates which is why the 504 program is so advantageous
for small business owners because the commercial loan that they
partner with, we partner with on the first, they price that however
they would price a typical commercial loan. But the SBA thought
the portion that we finance, because it is a split loan, basically, is
fixed for 20 or 25 years. So that is why they are seeking out this
program.
Mr. MEUSER. Okay. Mr. Flores, you mentioned a word before
‘‘stability.’’ I think any business would appreciate that thought and
that level of consistency. So why do you not expand? What are you
hearing from your clients?
Mr. FLORES. So, inflation, labor shortages, and supply chain
constraints are big problems. And we need to understand there are
still a lot of business out there suffering, particularly in the hospi-
tality industry. So, when we think about opportunities to strength-
en programs that we know have a positive track record, at the min-
imum, we should work strengthening these programs.
Mr. MEUSER. True.
Mr. FLORES. And that stability and being able to count on some
support is critical. So, I am just going to use this opportunity to
say, looking at ways to making sure that 504 program is ade-
quately funded is critical.
Mr. MEUSER. Okay. And that is very important. My time has
run out but I do want to hear from you if we have a second round,
or later, even in writing. You deal in the real world so any im-
provements—you started expanding on this, Ms. Mirenda, I would
love to hear more from you on that.
So, I yield back. Thank you.
Chairwoman DAVIDS. Thank you. The Ranking Member yields
back.
And the Chair now recognizes Congresswoman Chu for 5 min-
utes.
Ms. CHU. Mr. Doi, thank you for joining the Committee today
to share the incredible story of PACE for the congressional record.
Since you are an agency in Los Angeles, which is my area, I have
known of the incredible success of PACE for many, many years,
and I know how much you have done to help the most vulnerable
communities be able to become successful in small business.
So, as we examine the work SBA did with the Paycheck Protec-
tion Program, I appreciate that this Committee is taking note of
PPP’s initial challenges in reaching the smallest businesses and
how the reliance on community lenders such as yourselves and
community development corporations helped bridge that gap. I
have long been a proponent of the Community Advantage program
which aims to serve many of the same underserved and micro busi-
nesses. One proposal I have long been working towards would be
to lift the loan cap that Community Advantage lenders could issue
from $250,000 to $350,000. Can you discuss the benefits of lifting
the cap on the types of businesses that you serve?
Mr. DOI. Thank you for the question, Congresswoman.
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It would be of tremendous benefit. Hundreds of businesses come
to us every year. Many of them new entrepreneurs. We provide a
whole lot of business counseling to these small businesses prior to
offering them microloans, anything under $50,000. And as my testi-
mony indicated, it is averaging $10,000 loans. But as we continue
to work with them and help them grow where they learn business
basics, a business bootcamp, if you will, and they grow. Also, in my
written testimony I talked about one business that we provided a
$500,000 loan to that ended up hiring 20 employees. And so, lifting
the cap on the Community Advantage Program would help tremen-
dously as these types of businesses grow from being micro to reg-
ular bankable small businesses.
Ms. CHU. Thank you for that.
Mr. Doi, in your written testimony you alluded to work PACE
does in assisting refugees and those who sought asylum in the U.S.
I have heard so many inspirational stories of those that you have
helped who maybe did not have the credit history and all kinds of
circumstances that they face. In particular, your testimony tells the
story of my constituent, Don Wong. Because he was an asylee, Don
had limited business credit history so he was not able to get that
traditional loan, but PACE helped him secure the loan he needed
to purchase a new truck to begin his own trucking business from
the Ports of Los Angeles and Long Beach, helping to relieve the
supply chain backlog that we are all experiencing in this country
today.
With the nation’s attention on the needs of refugees, such as
those coming here from Afghanistan or Ukraine, Mr. Doi, can you
discuss the type of work PACE does in particular to assist refugees
starting their own businesses? What kind of impact does this work
have on the economy of the Los Angeles area?
Mr. DOI. Thank you again for that question, Congresswoman.
Yes. In working with asylees, as well as refugees, most of them
do not understand all of the culture, the nuances of America. And
so, we provide not only small business counseling, but social serv-
ices counseling also so that they understand the rules, the regula-
tions, business licensing, permits, reporting to IRS and accounting.
All of those kinds of things. And so, I want to reemphasize the
need for technical assistance. It is, indeed, important as we take
these people that for many reasons do not have the local work ex-
perience, do not have the local education, et cetera, but they do
have the entrepreneurial drive. And therefore, can put food on the
table and a roof over their heads. And so that is why this program
is so critical.
Ms. CHU. Thank you. And I yield back.
Chairwoman DAVIDS. Thank you. The gentlewoman yields back.
The Chair now recognizes, Rep. Kim, Ranking Member of the
Subcommittee on Innovation, Entrepreneurship, and Workforce De-
velopment.
Ms. YOUNG KIM. Thank you, Chairwoman Davis, and Ranking
Member Meuser, for hosting this hearing. And I want to thank all
of our witnesses for joining us today.
Over the last 5 years, one of the local CDCs serving my district,
the California 39th District, is CDC Small Business Finance. And
this has provided over 24 small businesses with financing over $34
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million and supporting 667 jobs. For this CDC, it is just a snapshot
of what successful private-public partnerships can do to deliver
much-needed capital to allow small businesses to expand and gen-
erate jobs in our communities.
I have helped introduce a number of 504 bills, including the 504
Modernization and Manufacturing bill that Mr. Manny Flores men-
tioned today. This bill also includes several new policy goals for the
program, including workforce development, which we now know is
an ongoing issue for employers across the country.
So, I want to ask you, Mr. Flores, what do you think, or can you
anticipate the type of benefit that would come from including work-
force development in the policy goals of the program?
Mr. FLORES. Thank you, Madam Congresswoman.
It sends a powerful message. It tells everybody who is applying
for a 504 loan who is working in the manufacturing sector that we
need to continue to focus on preparing a ready workforce that is
going to meet the demands of our dynamic marketplace today. Not
tomorrow, today. I often speak to a lot of businesses who are hav-
ing labor shortage issues. Oftentimes we hear that small busi-
nesses cannot find people to employ with the skills needed to meet
their needs. So, anything that we can do to promote workforce de-
velopment and training is a very positive thing to do and tying it
directly to a 504 program that is all about job creation makes a lot
of sense. So, we strongly support those efforts and I think it would
be very well received in the marketplace.
Ms. YOUNG KIM. Right. We are working hard to pass that bill,
H.R. 1490, so thank you. I hope to see this stand into law quickly.
And Ms. Mirenda, as you mentioned in your testimony, the CDC
industry is still awaiting the implementing the ALP Express Pilot
program. How has this delay implementing the pilot program im-
pacted the CDC industry and small businesses, and do you think
the SBA would benefit from the pilot program by getting loan proc-
esses off their plate?
Ms. MIRENDA. Thank you for the question.
Yes. It was passed in the Economic Aid Act in December of 2020,
and so we are still waiting on the implementation of the ruling.
And ALP Express, what that would do is that would allow us as
ALP lenders, which is Accredited Lender Program to unilaterally
approve SBA loans. And right now, SBA’s turnaround times are
very long. Just as far as 327 actions are concerned, 327 actions are
any changes made after an authorization is granted to us. And so,
any of those changes, they are taking up to 18 business days,
which is over 3 weeks. And so that is really affecting our small
business owners. That is where I think ALP Express would come
into play where we can unilaterally make decisions. And I am sure
we would be vetted by OCRAM, which they would come in and
audit us and audit our financials and the things that they do, but
that would be okay because we are proven CDCs.
Ms. YOUNG KIM. And so let’s look at the 504 program with
tasking the premier economic development program at the SBA for
decades. And it really has made things strong bipartisanly
throughout the years. So, in your estimation, Ms. Mirenda, what
are the main drivers or hallmarks behind this continued bipartisan
effort?
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Ms. MIRENDA. I would say the first thing is it operates on a
zero subsidy. I think that is important to both parties. Second is
we have a job creation goal. There is an economic job creation goal
or an economic impact that for every single 504 loan we do and the
default rate, I mean, default rate for 10 years is .6 percent. So, it
would be hard to argue on either side why the 504 loan program
is not advantageous for small business owners.
Ms. YOUNG KIM. Well, thank you so much. Thank you for being
here, again, and I yield back.
Chairwoman DAVIDS. Thank you. The gentlewoman yields back.
The Chair now recognizes Rep. Bourdeaux for 5 minutes.
Ms. BOURDEAUX. Thank you, Chairwoman Davids, and Rank-
ing Member Meuser for holding today’s hearing.
Community lenders are critical to expanding access to capital for
small businesses, in particularly those in undeserved markets, in-
cluding many in my congressional district. One of the clearest ex-
amples of this is the PPP program which showed how important
it is to support community-based lenders and the work that they
are doing every day.
This is a question for Mr. Doi. I really appreciate the technical
assistance and outreach that you do to small businesses. And one
of the things that we found around the PPP loan program was that
a lot of our really, really small businesses did not know about the
loan and really needed a lot of proactive technical assistance. I
went and talked to them and it seemed like we almost needed to
go into their barber shop, into their restaurant, set up a laptop,
and walk them through the program because they just did not have
the lawyers and the accountants and all of that backing support.
All of their energy was being thrown into just trying to keep their
business up and running.
And so, I was wondering if you could talk a little bit more about
technical assistance and what is needed in terms of a more
proactive effort to go out there and really support some of our
smallest of small businesses and make sure they can access things
like the PPP Loan Program or the Microloan program through the
SBA?
Mr. DOI. Thank you for that question, Congresswoman. You
have pointed out a really big issue in the small business commu-
nity. And it is not only in LA.; it is throughout the country. In talk-
ing to our colleagues throughout the country that are involved in
entrepreneurial development and growing new start businesses es-
pecially, they do not know. And even the ones that have been in
existence for 5 years do not know about all the various products
and services that are available to them. What is important is that
as a community-based lender that we participate in the economic
ecosystem. That would include the chamber of commerces, the
banking associations, other economic development organizations.
And that helps to spread the word. And even doing so is not
enough. I mentioned the need for language access. We are proud
to be able to say that our organization speaks over 40 different lan-
guages and dialects which is highly unusual for any organization
throughout the country. Because so many of these people where
English is not their first language do not know anything about the
services that are available. And I also mentioned the president’s
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Executive Order mandating language access. And it is so critically
important but it is an unfunded mandate. And so, adjusting the
formula for technical assistance would really help, especially in
outreaching to those that have never heard of these kinds of serv-
ices before.
Ms. BOURDEAUX. Thank you for that. And one of the commu-
nity projects I was very pleased to be able to get into the budget
was $100,000 for my Small Business Development Center to pro-
vide more in-language access. I have a very diverse community but
we have to kind of build our institutions to meet those needs. We
still are not in a place where an organization like yours is. It is
just taking us some time. We are much newer to that kind of diver-
sity so we are working on that.
One other quick question. One of the programs we talk about an
awful lot is the microloan program and that seemed to be a really
good fit for some of these really first-time entrepreneurs. Do you
have any recommendations of how Congress could continue to im-
prove this program and expand access for these small, often immi-
grant-owned businesses?
Mr. DOI. I do not like to be redundant but I do not think that
it hurts to continue to repeat that technical assistance is so impor-
tant, not only on the front end but on the back end. It is really an
important thing to have in-language business counseling, and so
that is why in our small business 101 workshops we do it in lan-
guage, in as many as eight different languages if necessary.
Ms. BOURDEAUX. Thank you so much. And I really appreciate
the good work you do. I yield back.
Mr. DOI. Thank you very much. Thank you.
Chairwoman DAVIDS. Thank you. The gentlewoman yields back.
The Chair now recognizes Rep. Van Duyne, the Ranking Member
on the Subcommittee of Oversight, Investigations, and Regulations.
Ms. VAN DUYNE. Thank you very much, Chairwoman Davids
and Ranking Member Meuser for holding this hearing.
Over the past 2 years, small businesses have faced seemingly
endless challenges to their overall survival. For months, we talked
about how ending the pandemic would return us to business as
usual but that is no longer the case. Months of stimulus and overly
generous unemployment benefits have resulted in excessive de-
mands, hobbled supply chains, and extremely tight labor markets.
And now small business owners are being forced to react to these
economic realities.
The NFIB February Small Business Report found that 68 percent
of small businesses have raised prices and almost half cannot fill
staff positions as nominal wages rise at the fastest pace in decades.
The administration’s unsustainable relationship with spending
money we do not have has led us to the next new business crisis,
record high inflation, numbers we have not seen since the early
1980s. And in response, the FED and lenders have begun to raise
rates adding yet another cost increase to their thin margins.
We would make one thing very clear today. Regardless of how
good SBA is at facilitating lending, that cannot make up for the
anti-growth environment created by this administration. The NFIB
report emphasizes this with zero percent of small business owners
reporting financing as their top issue while inflation, labor, and
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taxes top their concerns. Unfortunately, this administration ap-
pears not to have learned its lesson. Amidst our runaway inflation,
the president’s budget released yesterday included a more than
$1.1 trillion deficit next year and a $6.5 trillion deficit over the
next 5 years. It is time to reverse course and for this Congress to
emphasize fiscal responsibility by ending unnecessary spending,
clawing back fraud, and addressing actual pressing issues like the
Medicare Trust Fund that goes insolvent in 2026.
I want to thank our witnesses for their testimony today and for
Ms. Mirenda, I appreciate your testimony. We have all seen and
read articles about the massive amount of fraud in SBA programs
over the last 2 years. NBC News just released a piece yesterday
claiming that the SBA’s PPP program is the ‘‘biggest fraud in a
generation.’’ And they said the SBA basically said to people apply
and sign. What did not happen was even minimal checks to make
sure that that money was getting to the right people. And now the
SBA wants to get into the direct lending business. Do you believe
the SBA can underwrite and service small business loans as effi-
ciently and as prudently as you do?
Ms. MIRENDA. Thank you for your question. I do not think it
is a good idea for SBA to do direct lending. The reason for that is,
the reason our 504 program works so well is because we have a
dual underwriting process with a lender and there is a fiscal re-
sponsibility with the lender. And an example would be EIDL. I
mean, we were at dinner last night and a woman came up to us
about their EIDL loan and that is direct lending right now with
SBA. So, it is my professional opinion that, no, I do not think that
would be a wise decision. I think maintaining the 504 as my col-
league has pointed out, making sure this program stays open and
stays viable, the programs that are clearly working, that are part-
nership programs. Even the CA loan program that we facilitate is
working very, very well. So that would be my response.
Ms. VAN DUYNE. Do you think that the relationship that you
have with your banking clients actually has led you to have less
fraud because you know actually who you are loaning money to and
you are able to actually put that due diligence in that the SBA has
not been able to do?
Ms. MIRENDA. Yes. I think that partnership is imperative. I
mean, they are regulated as well, and so are we by the SBA. But,
yes. I mean, you mentioned PPP. The lenders did it really well and
I am not sure what group made CFIs but that worked really well,
too, community financial institutions that were doing the smaller
PPP loans as well. That was something that changed and I think
that the advantages as lenders are doing all their due diligence be-
cause they have to. They have to know their customer. They are
required to. So that is why this partnership works very, very well
in the 504.
Ms. VAN DUYNE. I really appreciate your responses here today
and I yield back.
Chairwoman DAVIDS. Thank you. The gentlewoman yields back.
The Chair now recognizes Rep. Donalds for 5 minutes.
Mr. DONALDS. Thank you, Madam Chair. I am going to do
something we typically do not do. I am not going to use my full 5
minutes. I just wanted to actually recognize Ms. Mirenda from the
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great state of Florida. Thank you for all the hard work that you
are doing on behalf of small business owners.
And with that, Madam Chair, I yield back.
Chairwoman DAVIDS. All right. Well, thank you. Thank you
again to our witnesses for testifying today. I also want to thank
you for all of the work that you have done for American small busi-
nesses since the pandemic began. This has certainly been a really
rough few years. As we know, small businesses are the foundation
of the American economy. Getting our economy back to full
strength depends on the well-being of our small businesses. The
pandemic recovery is certainly going to take time but we know that
the recovery is going to be jeopardized if the smallest of our small
businesses are not being thought of.
Accessing capital is a primary concern of a lot of small busi-
nesses, and we have to strive to ensure that certainly underbanked
and underserved businesses have access to the funding that they
need to be able to succeed. And as the Paycheck Protection Pro-
gram demonstrated [audio malfunction].
[Whereupon, at 10:59 a.m., the subcommittee was adjourned.]
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APPENDIX
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22
SBD026 with DISTILLER Insert offset folio 22 here 47180.004
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23
SBD026 with DISTILLER Insert offset folio 23 here 47180.005
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24
SBD026 with DISTILLER Insert offset folio 24 here 47180.006
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25
SBD026 with DISTILLER Insert offset folio 25 here 47180.007
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26
SBD026 with DISTILLER Insert offset folio 26 here 47180.008
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27
SBD026 with DISTILLER Insert offset folio 27 here 47180.009
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28
SBD026 with DISTILLER Insert offset folio 28 here 47180.010
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29
SBD026 with DISTILLER Insert offset folio 29 here 47180.011
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30
SBD026 with DISTILLER Insert offset folio 30 here 47180.012
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31
SBD026 with DISTILLER Insert offset folio 31 here 47180.013
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32
SBD026 with DISTILLER Insert offset folio 32 here 47180.014
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33
SBD026 with DISTILLER Insert offset folio 33 here 47180.015
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34
SBD026 with DISTILLER Insert offset folio 34 here 47180.016
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35
SBD026 with DISTILLER Insert offset folio 35 here 47180.017
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36
SBD026 with DISTILLER Insert offset folio 36 here 47180.018
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37
SBD026 with DISTILLER Insert offset folio 37 here 47180.019
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38
SBD026 with DISTILLER Insert offset folio 38 here 47180.020
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39
SBD026 with DISTILLER Insert offset folio 39 here 47180.021
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40
SBD026 with DISTILLER Insert offset folio 40 here 47180.022
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41
SBD026 with DISTILLER Insert offset folio 41 here 47180.023
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42
SBD026 with DISTILLER Insert offset folio 42 here 47180.024
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43
SBD026 with DISTILLER Insert offset folio 43 here 47180.025
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44
SBD026 with DISTILLER Insert offset folio 44 here 47180.026
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45
SBD026 with DISTILLER Insert offset folio 45 here 47180.027
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46
SBD026 with DISTILLER Insert offset folio 46 here 47180.028
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47
SBD026 with DISTILLER Insert offset folio 47 here 47180.029
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48
SBD026 with DISTILLER Insert offset folio 48 here 47180.030
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49
SBD026 with DISTILLER Insert offset folio 49 here 47180.031
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50
SBD026 with DISTILLER Insert offset folio 50 here 47180.032
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51
SBD026 with DISTILLER Insert offset folio 51 here 47180.033
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52
SBD026 with DISTILLER Insert offset folio 52 here 47180.034
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53
SBD026 with DISTILLER Insert offset folio 53 here 47180.035
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54
SBD026 with DISTILLER Insert offset folio 54 here 47180.036
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55
SBD026 with DISTILLER Insert offset folio 55 here 47180.037
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56
SBD026 with DISTILLER Insert offset folio 56 here 47180.038
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57
SBD026 with DISTILLER Insert offset folio 57 here 47180.039
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58
SBD026 with DISTILLER Insert offset folio 58 here 47180.040
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59
SBD026 with DISTILLER Insert offset folio 59 here 47180.041
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60
Æ
SBD026 with DISTILLER Insert offset folio 60 here 47180.042
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File and source
- File
- CHRG-117hhrg47180.pdf
- Size
- 44,305,718 bytes
- SHA-256
- d5df14d11818de6e4d3d1a32afe447ccf80e02c0d47252d10ac563bda90fe497
- Our copy
- CHRG-117hhrg47180.pdf
- Original
- www.govinfo.gov